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    aufiletter.htm

    AUSTRALIAN FOREST INDUSTRIES

      4/95 Salmon Street, Port Melbourne,
Victoria

      Australia,
3207

                                    March 28,
2008

    Ms. Tia
Jenkins

    Senior
Assistant Chief

    Accounting

    Office of
Emerging Growth

    Division
of Corporation Finance

    Mail Stop
7010

    Washington,
D.C. 20549-7010

    Re:          Multi-Tech
International, Corp.

    Form 10-KSB for the Year Ended December
31, 2005

    Filed May 19, 2006

    Form 10-QSB for the Quarter Ended March
31, 2005

    Filed June 22, 2006

    File No. 0-25909

    Dear Ms.
Jenkins:

    This is
in response to your comment letter of August 8, 2006 to Michael Timms with
respect to the above-referenced filings.  The numbered paragraphs
below provide answers and explanations to the corresponding numbered questions
and comments in your letter of August 8, 2006.  In addition to
providing you with this letter, Australian Forest Industries (the “Company”)
is”

              ●

              simultaneously
      filing Amendment No. 1 (the “Amended Annual Report”) to the Annual Report
      on Form 10-KSB for the year ended December 31, 2005
  and

              ●

              providing
      you with a copy of the Amended Annual Report marked to show changes from
      the Annual Report on Form 10-KSB that was filed on May 19,
      2006.

    Form 10K for the Year Ended
December 31, 2005

              1.

              We
      have confirmed with EDGAR Filer Support that the name change is
      effective.

    Item 6. Management’s
Discussion and Analysis; page 6

              2.

              We
      have updated the Amended Annual Report to clarify that we earn revenue
      from one product, Structural Radiata Pine Timber
      (lumber).  Sales are recorded when a customer is
      invoiced.  While we sold more timber in 2005 (68,000 m3) than in
      2004 (48,000 m3), an approximate 13% decline in the selling price of
      timber impacted our revenue.

              3.

              Our
      Amended Annual Report has been modified to note that while the cost of
      logs has remained constant, the quality of timber, which is measured by
      the recovery of structural timber from a given log, has
      declined.  Additionally, direct and indirect labor costs have
      increased 19.6% from 2004 to 2005.

              4.

              We
      have expanded our discussion of liquidity and capital
      resources.  Historically, our major shareholder, Timbermans
      Group Pty. Ltd. (“Timbermans Group”), has covered any shortfall in working
      capital.  As of December 31, 2005, there were no liabilities
      associated with our working capital deficit that were past
      due.

    Financial Statements, page
F-1

    Audit Report, page
F-1

              5.

              The
      date has been corrected and a reference to the restatement has been
      incorporated into the opinion.  Footnote A of the Notes to
      Financial Statements has been expanded to include the disclosure required
      by paragraph 37 of APB 20.

    Balance Sheet
F-2

              6.

              The
      receivable from related parties of $273,175 relates to the net effect of
      transactions between the Company and Timbermans Group, which is the
      Company’s majority shareholder.  In 2004, the net cash advances
      between the two entities were $613, 473 which was offset by the assignment
      of the timber contract which was negotiated by the Timbermans
      Group.  We have further restated the financial statements to
      offset the receivable against the amount due to the Timbermans Group
      shareholders who advance funds to the company leaving a remaining balance
      of $386,835 due to the Timbermans Group shareholders at December 31,
      2004.

    Consolidated Statement of
Operations

              7.

              We
      reclassified part of the 2005 non-operating income section and included
      the amortization of the gain on the sale and leaseback transaction in
      operating income.  See restatement Note K for explanation of
      changes.  The gain on disposal of assets relates to gains other
      than the gain on the sale/leaseback of equipment and accordingly is
      considered non-operating income.

    Consolidated Statement of
Cash Flows

              8.

              We
      have revised this statement based upon the changes discussed in item 7
      above.

    Statements of Changes in
Stockholders’ Equity, page F-5

              9.

              The
      columns in the Edgar version have been aligned for the amended
      filing.

              10.

              We
      have expanded Note C to the Financial Statements to explain the $5,307,400
      investment made by Timbermans Group in the Company in
  2004.

    Note A- Accounting Policies,
page F-8

              11.

              We
      have expanded the revenue recognition policy to include the criteria in
      Staff Accounting Bulletin Topic
13:A:1

    Note B-Variable Interest
Entities, page F-8

              12.

              In
      2003, the Timbermans Group entered into an agreement with the Australian
      Government for the right to harvest the last significant undeveloped pine
      forest in Eastern Australia.  It then borrowed money from a
      group of investors and the National Australian bank to purchase a pine
      sawmilling and timber facility to process the harvested lumber through the
      Company.  Both the Timbermans Group and the Company are under
      common control.  The Timbermans Group by itself cannot repay its
      loans without financial support from the Company, and the Company will
      absorb the losses of the activities and will receive any future
      returns.  All of the assets of Integrated Forest Products
      including goodwill was pledged to secure the loan the Timbermans Group
      made to purchase the Company.  The common control Directors and
      Officers guaranteed the loan.  As such, we concluded that the
      Timbermans Group is a variable interest entity and the Company is the
      primary beneficiary and therefore must be consolidated in the financial
      statements under FIN 46R.

    Note E- Related party
Transactions, page F-9

              13.

              The
      Timbermans Group paid cash for the Long-Term Log Supply
      Contract.  The disclosure was erroneously included under
      operating.  It is now included under
  Investing.

    Note F-Short Term Borrowing,
page F-10

              14.

              We
      have expanded Note G to the Financial Statements to clarify the terms and
      conditions of the $790,000 guarantee with the South Wales
      government.  Since this is a guarantee, amounts have been
      recorded in the Financial
Statements.

              15.

              We
      have disclosed the terms and conditions of all financial agreements in
      Note G to the Financial Statements.

    Note K-Sale-Leaseback
Transaction, page F-11

              16.

              We
      have revised the disclosure and have restated the 2005 Financial Statement
      to reflect the amortization of the gain over a 30 year period, the life of
      the related assets as called for by SFAS
98.

    Item 8, Change of
Accountants, page 9

      17.

               Disclosure
      of the change in accountant as it appears in Item 8 of Form 10-K for the
      year ended December 31, 2005, filed on May 19, 2005, satisfies all
      disclosure requirements.

    Item 8A, Disclosure Controls
and Procedures, page 9

      18.

              We
      have added the following sentence to Item 8A, (a)(ii): “The Company's
      management, including the CEO and CFO believe that our system of
      disclosure controls and procedures provide reasonable assurance that
      information required to be disclosed in our periodic reports filed under
      the Exchange Act is, in fact, being
disclosed.”

    Exhibits 31.1 and 31.2,
Section 302 Certifications

      19.

               We
      have revised the revised certifications to conform with the language that
      is required by Item 601(b)(31) of Regulation
  S-B.

      20.

              We
      are in the process of amending our quarterly report on Form 10-QSB for the
      period ending March 31, 2005 and will file it shortly
      hereafter.  We intend to revise the certifications per your
      instructions.

              21.

              We
      are in the process of amending our quarterly report on Form 10-QSB for the
      period ending March 31, 2005 and will file it shortly
      hereafter.  We intend to include the following statements in
      Item 2 of that amended Form 10-QSB:

    CAUTIONARY
STATEMENT REGARDING FORWARD LOOKING STATEMENTS

          It
should be noted that this Management's Discussion and Analysis
of      Financial Condition and Results of
Operations may contain "forward-looking statements." The terms "believe,"
"anticipate," "intend," "goal," "expect," and similar expressions may identify
forward-looking statements. These forward-looking statements represent the
Company's current expectations or beliefs concerning future events. The matters
covered by these statements are subject to certain risks and uncertainties that
could cause actual results to differ materially from those set forth in the
forward-looking statements, including the Company's dependence on
weather-related factors, introduction and customer acceptance of new products,
the impact of competition and price erosion, as well as supply and manufacturing
restraints and other risks and uncertainties. The foregoing list should not be
construed as exhaustive, and the Company disclaims any obligation subsequently
to revise any forward-looking statements to reflect events or circumstances
after the date of such statements, or to reflect the occurrence of anticipated
or unanticipated events. In light of the significant uncertainties inherent in
the forward-looking information included herein, the inclusion of such
information should not be regarded as a representation that the strategy,
objectives or other plans of the Company will be achieved. The Company wishes to
caution readers not to place undue reliance on any such forward-looking
statements, which speak only as of the date made.

    RESULTS
OF OPERATIONS

         We
are currently in the third year of operations and have generated significant
revenues to date. Our activities from inception to date were related to our
formation, preparation of our business model, arranging and planning financing
and the acquiring all rights, title and interest to our timber rights located in
the Canberra region in addition to the implementation and construction of our
first sawmill also in the Canberra region.

          Operating
costs for the three-months ended March 31, 2006 aggregated $4,327,928. This
includes costs incurred in procuring our rights under the Bombala Agreement and
operating expenses for our Canberra sawmill. We incurred an operating loss of
$(878,816) and a total net loss of $(601,629) or $(0.01) per share.

    LIQUIDITY
AND CAPITAL RESOURCES

    On March 31, 2005 we had current
assets of $5,375,750.  Net cash used in operating activities for the
three month period ending March 31, 2005 was $(323,276).  Net Cash
used in Financing Activities for the three month period ending March 31, 2006
was $2,587,969.

    Controls and
Procedures

      22.

              We are in the process of amending
      our quarterly report on Form 10-QSB for the period ending March 31, 2005
      and will file it shortly hereafter.  We intend to include the
      following statements in Item 3 of that amended Form
      10-QSB:

    ITEM 3.
CONTROLS AND PROCEDURES

    The
Company's management, including the CEO and CFO believe that our system of
disclosure controls and procedures provide reasonable assurance that information
required to be disclosed in our periodic reports filed under the Exchange Act
is, in fact, being disclosed.

    (a) Our
principal executive officer and principal financial officer have each evaluated
the effectiveness of our disclosure controls and procedures (as defined in
Exchange Act Rules 13a-14 and 15d-14) as of a date within 90 days prior to the
filing date of this quarterly report and have each concluded that our disclosure
controls and procedures are adequate.

    (b) There
were no significant changes in our internal controls or in other factors that
could significantly affect these controls subsequent to the date of their
evaluation, including any corrective actions with regard to significant
deficiencies and material weaknesses.

    (c) Not
applicable

    Financial
Statements

              23.

              We
      are in the process of amending our quarterly report on Form 10-QSB for the
      period ending March 31, 2005 and will file it shortly
      hereafter.  We intend to revise the financial statements to add
      the disclosure relating to SFAS
123R

    1934 Act Periodic
Reports

              24.

              With
      this letter, we are simultaneously filing the restated financials for the
      year ended December 31, 2005 in the Amended Annual Report.  We
      will also file a current report on Form 8-K providing the required
      disclosure under Item 4.02 thereof for the quarters ended March 31,
      2005, June 30, 2005 and September 30,
2005.

    25.
Amended quarterly reports for periods ended March 31, 2005, June 30, 2005 and September 30, 2005 will be filed
in the Company's second quarter of 2008.

    26. Today we filed the following documents as exhibits to our
amended 10-KSB for period ended December 31, 2006:

        a. Loan
Document for Timbermans Group Pty Ltd.

        b. Loan
Document for Integrated Forest Products Pty Ltd.

        c. Deed
of Sale

        d.
Sale/leaseback document

              27.

              We
      note your comment and understand its
importance.

    We hope that the above letter and the
Amended Annual Report satisfactorily address the comments and questions raised
in your letter of August 8, 2006 and apologize for the delay in responding to
that letter.  If you have any additional questions or comments, please
do not hesitate to contact me or the Company’s counsel, William Rosenstadt (tel.
212-588-0022: email wsr@sovrlaw.com).

    Best
regards,

    /S/
Michael Timms

    Michael
Timms

    Chief
Executive Officer, President

    cc:           Maureen
Bauer, Securities and Exchange
Commission

    Carlton Tartar, Assistant Chief Accountant,
Securities and Exchange Commission

    John Reynolds, Chief, Securities and Exchange
Commission